ML20235H762

Fuel Shipment QA Program

ML20235H762
Person / Time
Site:	07100670
Issue date:	02/08/1989
From:	WORCESTER POLYTECHNIC INSTITUTE, WORCESTER, MA
To:
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ML20235H756	List: ML20235H754 ML20235H762
References
NUDOCS 8902240028
Download: ML20235H762 (30)

Text

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1 Worcester Polytechnic Institute Quality Assurance Program February 8, 1989 4e FUEL SHIPMENT QUALITY ASSURANCE PROGRAM WORCESTER POLYTECHNIC INSTITUTE NUCLEAR REACTOR FACILITY WORCESTER, MASSACHUSETTS i

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.c Lis Worcester Polyt'echnic Institute Quality _ Assurance Program February 8,.1989 c..

TABLE OF CONTENTS

.Section' Pace L1. O INTRODUCTION

L.1 ~

Purpose' 1

1.2' Applicability 1

1.3

References 1

2.O PROGRAM REQUIREMENTS 1

2.1 Responsibility 1

2.2

-Organization 3

2.3.

Documentation 3

2.4 Procurement Control 4-2.5' Material ~ Control 5

2.6

' Process Control 6

2.7 Inspections 6

2.8 Test Control 7

2.9 Measurina and Test Eauipment 7

2.10. Nonconforming Material and Parts 7

' 2.11' Cor.rective Action 7

2.12' Ouality Assurance Records 7

2.13 Audits.

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- 3. 0' FIGURES 4.0 FORT'S -

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L February 8, 1989 1.0' INTRODUCTION 1.1'Purposo

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d The purpt, 7f this document is to provide

.requireme. - for managing, conducting, and auditing the Fuel Shipment Quality Assurance i

Program at Worcester Polytechnic Institute. (WPI) 1.2 Applicability The Quality Assurance Program applies to those quality assurance activities related to transportation of fuel from the WPI Nuclear

-Reactor Facility.

1.3 References American National Standard Institute (ANSI)

N402-1976, Quality Assurance Program Requirements for Research Reators.

Code of Federal Regulations, Title 10, Title-49

'2.0 PROGRAM REQUIREMENTS 2.1 Responsibility The Radiation', Health and. Safeguards Committee (RHSC) is responsible for establishing the facility's quality assurance policies,-goals, and objectives. The Reactor Facility Director retains overall authority and responsibility for the administration of the Quality Assurance Program.

2.1.1 Worcester Polytechnic Institute Radiation.

Health and Safeauards Committee Charter The RHSC shall be responsible for recommendations relating to the safe operation of the WPI reactor.

They shall also make recommendations relating to quality assurance and compliance with U.

S.

Nuclear Regulatory Commission regulations as well as other rules and regulations they deem appropriate.

Recommendations shall normally

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be made to the reactor director, but if the committee believes appropriate, they shall be made to the WPI provost.

2.1.1.2 The RHSC shall hold at least four meetings each year, at least one each in January, July, October and April. Additional meetings shall be called by the chairman or secretary at the request of any committee member.

4 Whenever possible, meeting notices shall be mailed out to all committee members at least one week in advance of the meeting.

2.1.1.3 A quorum shall consist of four committee members.

Sub-committees may be appointed at the discretion of the RHSC chairman.

2.1.1.4 The Radiation, Health and Safeguards Committee shall review and approve all proposed modifications affecting reactor safety, and general and specific types of experiments and procedures, including determination of unreviewed safety questions pursuant to 10 CFR Section 50.59.

This committee shall also conduct, at least quarterly, audits of operations, equipment performance, records and procedures.

2.1.1.5 The Committee shall vote to approve or disapprove of the results of its quarterly audit of the reactor's operation and maintenance programs and shall recommend corrected action as required.

The RHSC shall follow up on recommended changes.

2.1.1.6 Minutes shall be kept of all RHSC meetings and copies shall be distributed to all committee members.

2.1.2 Ouality Assurance Approval / Responsibility 2.1.2.1 This Quality Assurance Program and any future revisions shall be approved by the RHSC.

2.1.2.2 Activities as outlined in this Quality Assurance Program may be subcontracted, however the responsibility for these activities remain that of the Reactor Facility Director.

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4 2.1.3 Reactor Facility Director The Reactor Facility Director is responsible for:

Assigning Quality Assurance / Quality Control personnel Scheduling reactor activities, including quality inspections and audits Assigning drawing and document numbers as required Submitting safety analysis and project design to the RHSC for a t roval as required.

Submitting license and technical specification amendments to the NRC as required Maintaining a project file that contains copies of all records associated with the project Maintaining properly calibrated measuring and test equipment.

i 2.1.4 Ouality Assurance Audit The Quality Assurance Audit will be performed

-at the end of the shipping process. (See 2.13) 2.2 ORGANIZATION 2.2.1 Refer to figure 1 for the WPI reactor organization.

2.2.2 The Reactor Facility Director has the 4

responsibility for implementing the Quality Assurance requirements of this program.

2.3 DOCUMENTATION All activities affecting fuel transportation will be formally identified and documented.

Documentation will include the applicable procedures, reviews, and other measures to be applied.

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2.4 PROCUREMENT CONTROL Applicable codes, standards, and regulatory requirements will be included in procurement documents.

Procurement documents will require contractors or subcontractors to provide appropriate quality assurance controls, which may include, but are not limited to, functions such as inspections, tests, and controls over materials, processes, and.nonconformances.

2.4.1 Procedures will be established on a project basis that clearly delineate the sequence of actions to be accomplished in the preparation, review, approval, and control of procurement documents.

2.4.2 A review and concurrence of the adequacy of quality requirements stated in procurement documents will be conducted by the Reactor Facility Director.

The review will: determine that quality requirements are correctly stated, inspectable, and controllable; there are adequate acceptance and rejection criteria; and the procurement document has been prepared, reviewed and approved in accordance with Quality Assurance Program requirements.

2.4.3 The review and approval by the Facility Director of procurement documents will be documented prior to release.

2.4.4 Procurement documents will identify the applicable 10 CFR and 49 CFR requirements which must be complied with and described in the supplier's quality assurance program.

The supplier's quality assurance program or applicable portions thereof will be reviewed and concurred with by the Reactor Facility k

Director prior to initiation of activities affected by the program.

2.4.5.

Procurement documents will contain or reference the design basis technical requirements including the applicable regulatory requirements, material and component identification requirements, drawings, specifications, codes and

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l industrial standards, test and inspection requirements, and special process instructions.

2.4.6 Procurement documents will identify the documentation (e.g.,

drawings, specifications, procedures, inspection and fabrication plans, inspection and test records, personnel and procedure qualifications, and chemical and physical test results of material) to be prepared, maintained, and submitted to the Reactor Facility Director for review and approval.

2.4.7 Procurement documents will identify those records to be retained, controlled, and maintained by the supplier, and those-delivered to the facility prior to use or installation of the hardware.

2.5 MATERIAL CONTROL Control of the identification, handling, storage, shipping, cleaning, and preservation of material will be established as deemed necessary by the Reactor Facility Director.

2.5.1 Nonconforming material or parts will be identified, segregated, and evaluated.

Evaluation will be acceptance, repair, I

rework, or rejection.

2.5.2 Special handling, preservation, storage, cleaning, packaging, and shipping requirements will be established and accomplished by reactor facility personnel in accordance with predetermined work and inspection instructions.

2.5.3 All necessary shipping papers will be prepared as required.

2.5.4 All conditions of the Nuclear Regulatory Commission package approval and the United States Department of Transportation shipping requirements will be satisfied prior to shipment.

2.5.5 Departure time, arrival time, and 5

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destination of.a package will be established and monitored to a degree l

consistent with safe transportation of i

the package.

2.6 PROCESS CONTROL Processing of fuel'and containers will be accomplished I

under controlled conditions in accordance with applicable codes, standards, and specifications.

Procedures will be written for those special processes not covered by existing codes or standards.

2.6.1 Special processes such as nondestructive testing, and cleaning will be controlled through compliance with written l

procedures and inspections.

2.6.2 Identification of the inspection, test and status of fuel and containers will be controlled so that they are known throughout the shipping process.

2.6.3 Application and removal of status indicators such as tags, labels, and stamps will be controlled through compliance with written procedures.

2.7 INSPECTIONS Inspection requirements-apply to procurement, container loading and vehicle loading and will include, to the applicable extent, the following:

a) Inspection procedures, specifying the characteristics to be inspected, sampling plans, and acceptance criteria.

b)

Description of process monitoring action for those situations in which inspection is impossible or disadvantageous.

c)

Specification of mandatory points of inspection.

d)

Procedures for identifying inspection and test status, so that only items that have passed the required inspections and tests are used.

Nonconforming items will be clearly identified, i

2.7.1 Inspection program which certifies conformance of quality-affecting 6

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activities'with requirements will be established, documented, and-accomplished.in accordance with written procedures.

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Measures will be taken and documented to determineLthe validity'of previous inspections performed _when measuring or test equipment is found to be out of.

calibration.

2.8_

TEST CONTROL 1

The test program will cover required tests.

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. Test procedures will specify appropriate prerequisite and

. monitoring requirements, equipment to be used, personnel training requirements, suitable environmental conditions, and provisions for documentation as applicable..

2.9' MEASURING AND TEST EOUIPMENT Tools, gages, instruments,-and other neasuring and testing' devices used in fuel shipping activities will be

available, and properly calibrated, or adjusted as appropriate at 1

the required intervals.

2.10 NONCONFORMING MATERIAL AND PARTS LAll nonconforming fuel. shipping material, shall be identified,'and segregated fron acceptable material.

2.11 CORRECTIVE ACTION Significanticonditions detrimental to quality of fuel shipping items, such as failure, malfunctions, and deficiencies, shall be promptly identified, the cause determined, and corrective action taken to preclude' repetition.

2.12 OUALITY ASSURANCE RECORDS The Quality Assurance Program is based upon documentary evidence of all activities affecting quality of fuel transportation related items.

Records maintained shall include as minimum: Inspection, and Test'results, results of Quality Assurance reviews, Monitoring actions, Audits, Material analyses, Procedures used in Quality Assurance Program Records.

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2.12.1 All records shall be identified and retrievable.

2.12.2 The Reactor Facility Director shall maintain the quality assurance records.

2.12.3 The retention period for fuel shipping records shall be for three years following the end of the fuel shipping process.

2.13 AUDITS Audits shall be performed at the end of the fuel shipping process by a designated independent member or members of the RHSC. The audit results shall be reported on the Audit Report form. The report shall be forwarded to the Reactor Facility Director, with copies to the Radiation, Health and Safeguards Committee.

i 2.13.1 Deficient areas will be noted and corrective action taken.

Deficient areas will be reaudited on timely basis to verify implementation or corrective action taken to minimize reoccurrence of deficiencies.

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Figure 1-WPI Reactor Organization WPI Provost t

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' Radiation, Ilealth, and' f

I Safeguards Committee

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7' Reactor Facility Radiological Director

. Safety.

Officer y

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i Reactor Faci.11ty

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l Form QA-1 Procurement l

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-a Date:

Item

Description:

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certificate of Compliance or other certification :

Applicable codes and standards:

Record-keeping Requirements:

Acceptance or Rejection and criteria:

Facility _ _ _ _ _ - - = -Director i

u______._._____

g________

4 Form QA-2 Nonconforming Items

.Date:

Identification'of. Item:

Discrepancy or Nonconformance:

s I

L Signature

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Disposition / Action Taken Date:

___ Acceptance Criteria:

.___'Repalr/ Rework

==

Description:==

I

___ Rejection i

i submitted- - - - _ - -

- - - = =. Facility Director

b Form QA-3 Quality' Assurance Audit

.Date:

i Audit of QA activities and documentation Comments:

Deff icient-areas:

~ Follow-up activ.ities:

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Procedures for HEU shipping using a-DOT 6M type B Container Container Procurement i

Notation is made'on form QA-1 that the procurement documentation contains a-Certificate of Compliance for the container, and a~ quality assurance program is given for the container, identifying the 10 CFR.

and 40 CFR compliance requirements, and that record-keeping requirements are specified.

Any' nonconforming items should be noted on form QA-2.

I Shipment Notificat$on requirements At least seven days before the shipment is scheduled,,the organizations listed below must be notified in writing with the

.following'information:

Route of shipment, time and datc that shipment w i,l l arrive in the area (as exact as possible), truck identification (license number, etc.), material identification (chemical form, weight, description, etc.), destination, identification of WPI as shippers, and emergency numbers to contact.

All of the information must be marked " Safeguards Information" on an inside envelope. Any changes in information should be made as soon as possible, with telephone notification acceptable with changes being only referenced i

to the original date (i.e.

" days before" or " days after")

Organizations Massachusetts Department of Public Health Radiation Control Program 150 Tremont Street Boston, MA 02111 (617) 727-6214 Department of Environmental Protection 165 Capital ~ Avenue Hartford, CT 06106 Attn: John W.

Anderson

-(203) 566-2110 Application with $25.00 fee must be previously sent 1

New York State Emergency Management Office Donald A.

DeVito, Director State Campus Public Security Bldg. #22 Albany, NY 12226-5000 contact: Mike Trier (518) 457-9972 Pennsylvania Emergency Management Agency

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P.O.

Box 3321 Harrisburg, PA 17105 Attn: George M.

Johnson, Director

-(717) 783-8150

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, - ($1000' required,ifor.eNcort

'e Maryland St' ate Police.

1201: Reis t e r town: Rd,

Pikesville,fMD' 21208-3899 Attn': L t'..

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J.

A.

Jones

(301) 631-4212 1

DepartmentLof Public Safety LWest Virginia State Po' lice 725--Jefferson Road South Charleston, WV -25309 Attn:. Col, W.

F.'Donohue,: Superintendent contact: 0ary Morris, Office of Emerg. Services (304)'348-5380 Commonwealth'of. Virginia

. Department of Emergency Services.

310' Turner Road Richmond,'VA'

'Attn.: Harry.Broadas (804) 674-2416 Application for registration previously sent.

Tennessee Emergency Management Agency 3041'Sideo Drive Nashville, TN-37204 (615)'252-3300 North Carolina State Highway Patrol L512?N. Salisbury Street P.O.. Box'27687 Raleigh,:NC 27611-7687 Attn: 1st Sgt.

C.

A.

Danieley.

. contact:

Janet Ferrell (919) 733-4030 South Carolina. Dept. of Health 2600 Bull Street Columbia, SC 29201

' Attn: Heyward G.

Shealy (803) 253-6497 Chie'f

' Materials Transfer SG Licensing Branch 1

Division =of Safeguards NMSS 4

U.S-Nuclear Regulatory Commission Washington,'DC 20555 U.S.

Nuclear Regulatory Commission Region I 475 Allendale Rd.

King of Prussia. PA 19406 (215) 337-5000 U.S.

Nuclear Regulatory Commission Region II 101 Marietta St.,

N.W.

Suite 2900

! Atlanta, GA 30323 (404) 221-4503

References:

10CFR 71.97

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. Container Receipt

.Each container will be brought into the Reactor Facility to a predetermined location.

The container-number will be noted and the container will-be visually. inspected to be free of non-superficial defectu and the container closures will be verified to be properly installed.

Noted on Form A.

An-exterior and interior wipe of not less than 100 cm* will be

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taken and a counts will be verified to be less than 200 dpm.

AEp count will be verified to be less than 2000 dpm.

Both counts will be entered on Form A.

References:

10 CFR 71.85 Loading r, f container A fuel element will be raised from the reactor pool and the element number verified.

The element will be suspended to allow it to dry, placed into a plastic bag, and lowered into the GM container.

All fuel transferrals will be made as remotely as reasonably achievable.

An interior wipe will be taken and the container will then be closed and sealed.

All surveys will be made using a monitor which has been verified to have been properly calibrated within the last calendar quarter.

A survey of the container sides, top, and bottom will then be made and the maximum reading will be noted and verified to be less than 200 mR/hr.

A survey of the levels at a radius of 1 meter from the container shall be taken and verified to be less than 10 mrem /hr, I

maximum.

An extr 1al wipe sample will be made.

The container will then be moved to a separate location so as not'to interfere with the measurements of a different container.

All data will be entered on Form B.

Under no circumstances is any loaded container to be left unattended or unalarmed prior to loading onto the truck.

All loaded containers are to be stored in a designated and clearly marked area in the reactor facility.

References:

10 CFR 71.87 10 CFR 71.47 10 CFR 73.67

. preparation for shipment The container will be visually inspected and the seals verified.

The container will then be verified to have markings of " Type B"

and

" USA" as well as the gross container weight (if over 110 lbs.)

The container will be verified to have a Radioactive Yellow III label on opposite sides of the container, with the activity as calculated and l

transport index (maximum radiation level at 1 meter, or 1.0, whichever 3

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'is larger)JmarkedJon the label.

Any labels with contrary.Information

-present on thelcontainer (1.e.

" empty" labels) are.to be removed or

/ defaced. Allflabeling is noted on Form D.

References:

~ 49 CFR 172 Subpart D (marking) 49 CFR.172.403 (labeling) 49 CFR 173.403 (bb)

(transport index)

'10 CFR 73.67e1(111)

(visual inspection)

Veh'icle loading The truck must first be given a preliminary survey to assure that no-radioactive material is present from a previous shipment.

At least two

'WPI Police officers'will be.present during all fuel movement'from the reactor. facility toJthe' truck.

One police officer will be stationed at the truck and the other will accompany all fuel movements outside.of the reactor.

The truck will'be loaded with the sealed containers secured against any movement with the proper tie-downs, capable of withstanding at least two (2) times the container weight in vertical force anditen (10) times the weight in horizontal force.

The truck

- should be verified to be placarded on four sides with " Radioactive" with the placards verified secured. Noted on Form E.

A survey should be made of the truck using Form F to verify the following radiation. levels:

.<.2' mrem /hr maximum in cab or sleeper

<.10 mrem /hr maximum 2 meters from surface of truck

< 200 mrem /hr on surface of truck The driver of the vehicle will then be given the following documents (noted on form G), signed by an officer of the college:

Radioactive Shipment and Receipt Record, Bill of Lading (Radioactive material Fissile III, N.O.S.),

Shipper's Declaration of Dangerous Goods, and Shipping'and Emergency Instructions, listed below.

The driver's survey meter will be verified to be properly calibrated and in working order.

Additionally, the driver's two-way communication device will be

. verified to be operable.

References:

10 CFR 71.45 (tie-downs) 10 CFR 71.47 (rad. levels) 1 4

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Shipping Instructions to carriers l

Notification in the event of delay or required changes in route The time scheduled for this shipment from departure to arrival is hours.

If it becomes apparent that delays for any reason will increase this time by five (5) hours or more, advise the WPI Nuclear

. Reactor Facility by phone, (508) 831-5276, of the new estimated time of arrival and the'cause of delay.

Any change in route must be cleared with the WPI Nuclear Facility before making the change.

Inspection by authorized officials en route This shipment is proceeding under the full compliance of all known regulations and with the authorization of all cognizant authorities.

At each port of entry, this Record and Receipt and the Bill of Lading should be presented for the inspection of the responsible authorities and they are to be permitted access to the truck and its load for their inspection purposes.

Under no conditions should anyone except the consignee be permitted to release tie-downs, break seals, or open containers without having written authorization from the WPI Nuclear Reactor Facility, i

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Notification in the Event of Emergency involving the shipment In the event of emergent y involving this shipment, notify:

1.

Local fire and police departments 2.

The WPI' Nuclear Reactor Facility I

(day)

(508) 831-5276 or (508) 831-5688 (night)

(508) 831-5433 (WPI Police) or (508) 831-5270 I

Measures to be taken in case of fire or accident 1.

There is no explosion hazard from the shipment.

2.

There is reasonable time to take action to avoid any radiological hazard in the event of fire.

3.

Keep sightseers back from the shipment - 50 yards 4.

Treat as petroleum fire --

use foam type blanketing agent or CO, extinguishers for small fires.

Avoid direct water streams that might tend to spread any solid radioactive particles.

5.

Use gamma radiation survey meters while approaching -- not to exceed 10 mR/hr.

5.

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' Route Lon The carrier = agrees'to stop at a safe-stopping place (at least--100 syards away.from any' building) periodically to check tire conditions and other mechanical conditions of the truck and to-log. time, place, and results of this inspection.

Additionally, the carrier is to

. periodically inspect the general condition of the shipment'and tie-downs..

The condition.of the tie-downs and other data are to be logged.

A copy'of the log'is to be.sent on arrival to the WPI Nuclear Reactor Facility, 100 Institute Rd.,

Worcester, MA 01609.

Additional Requirements Fissile. Class III shipments must be kept at least six.(6) meters from any other: packages bearing Radioactive Material labels.

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Form A 6M Receipt i'

Date:

r Container number t

Visual inspection:

Free of non-superficial defects Closures properly installed Comments:

Date counter calibrated

Wipe of exterior:

cpm a 4

i cpm p Wipe of interior:

cpm a epm p 4

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Facility

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T Form B Container Loading

'Date:

Container number:

Fuel Element number:

Element in plastic Element properly inserted Date counter calibrated:

Internal-wipe sample:

.a cpm p

cpm Container sealed External wipe sample:

a cpm S

cpm Survey meter used:

Date calibrated:

Maximum reading at side surface mR/hr top surface mR/hr bottom surface mR/hr Maximum reading at 1 meter mR/hr

__ Facility Director

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Form C Container Contents Date: _ _ _ _ _

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Container *:

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Element *: _____

Type (standard)

(experimental)

(Washington State) i-Date first placed in core:

Days in core:

Date removed from core:

. Days'since removal:

Composition Pre-Irradiation Post-Irradiation U:

g U: _

_______ g Pu:

g.

"*"U:

g

• • "U:

g

""*Pu:

g

• • • U:

g

• • • Pu:

g

"""U:

__ __ __ g Np:

_ __ g Th:

_______ g Energy generated:

MWt' days Total activity:

Ci Comments:

Signed:

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6 Form D Container Preparation Date:

h Cont'ainer Number:

LVisual Jnspection:

Seals:

Markings:

Type B USA gross weight:

lbs.

Labels:

Radioactive Yellow III Transport index:

Calculated activity:

- - - - -... - -.=_--------

Facility Director 3

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Form E Vehicle Loading 4

Date:

WPI-Police Officer present:

28 Containers loaded:

tie'-downs in" place and tested 4

Radioactive p.lacards ~ in place and secured t' ruck survey performed (Form F)

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,.. l Form F Truck Survey DLfu

' Truck 10 : n u m b e'r :

l Survey meter used:

Date Calibrated:

' NOTE: TIIIS IS TO BE USED WIT 11 SURVEY MAP A.

DS - Driver's Side PS - Passenfrrr's Side A - Below box-B - Midd1'e of box' C - Roof of box l

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1 30A.

__l Ont_ box _-.,PS__ _

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l 300.

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_L 31.

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_ J_200 _,.J_

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33A.

L B,e l_g w box 2_0_0,_ _j

.1 L I n s i d e._b o x L _._ J L

i 338.

.3 3 C '. j Traller roof I 200

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34B.

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[ Trailer roof

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l'yl gy, box ,,,_.L200_,,_j _.____[ 36B. 'J_Inside_-box j 1 _,,J. 6.C.,_.1_ Trailer roof _ _L 2 0 0 1 .._L 3 NOTEi THE REMAINING POINTS ARE 2 METERS AWAY FROM THE TRAILER. 37. L DS _L 10 _ _ J _, 1 38. ' LD S. __ __L1,0 _ L, _1 _,_ _,3 9. j,_D,S ,,j,_ 1_0 l l _40. LD,S_ _l 10 41 LD S j __10 l 42. !' Rear .,_ _ _j 10 L ,_ _,1 43. L_ Rear J 10 l J. 41-LP S .._._1_1 0 l l 4 5. _ LP s__. _._, L 1 0 ,L. __ _ _ _.1 40. L._P s _ L1_0 l 1 _47- ~.L_P S _ L 10 l _L 48. I PS J 10 __1 J COMMENTS: 1 I' Surveyor Signature i Fac1]ity Director

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g Form G Documentation Delivery Checklist Date: Time: .. Delivered to driver: Initial 4 Bill of Lading Radioactive shipment and receipt rekcord Shippers declaration of dangerous goods Shipping and emergency instructions Houte verifJed with driver 1 Iicertify.that. I have received all t he 'above ina te rials. Driver's Signature l t Date driver's survey meter en)ibrated: v Driver's two-way communication operable i Facility Director

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-FCAF' LPDR 1& E REF. 7 SAFEGUARDS FCTC' l I DTHER. DATEblk~l. INITIAL I V ', i b, e ' i' ; t___in____211__________u__..__._l.____._ __.m.'_.____ _. _ _ _ _ _ _ _ _ _ _ _ _ _ _. _ _. _ _ _ _. _ _ _. _ _.... _ _ _ _ _ _.__________.___________s

g s.' i d V @ Ou70 o:su o. co w :a na. 25/13 DATE OF DDC. Aruc3rt '/d /7@ DATE ROVD. ' JT orudre' /9N FCUF- -PDR ~/ FCAF LPOR-I& E REF. - / SAFEGtJARDS fCTC -- OT!ill DATEI /N INITIAL I I v 1 -}}